HomeMy WebLinkAbout07.17.20 Shari McCracken - CARES Act COVID Relief Fund Allocation to Counties AT0
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Finance Process Overview
CARES Act Requirements and Treasury Guidance
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US Treasury Guidance
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Overview of Federal CARES Act Requirements for Coronavirus Relief Funds (CRF)Certification and Allocation TimelinesEligible Expenditures Compliance with State Public Health RequirementsReporting
and Records RetentionQuestions and Answers
Objectives
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related supplemental
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COVID
except
19 public health emergency.
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Direct responseSecond order effects such as economic support
Necessary expenditures incurred due to the COVIDNot accounted for in the most recently approved budget, appropriations or budget adjustmentsExpenses incurred between March 1, 2020 and
December 30, 2020.
CARES Act Requirements
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federal share of Medicaid
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be used to backfill lost revenue
cannot
Continue to receive updates (Last one 7/8/20)
Funds Cannot be used as nonPayroll or benefits for employee duties not Workforce bonusesDamages covered by insuranceAssistance to owners to pay property taxesItems disallowed in US Treasury
FAQs
CARES Act Limitations
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As the direct recipient of CRF, any disallowances will initially be recouped from the StateRequired to gather information and report to the federal government on use of fundsRequired
to perform subrecipient monitoring, including auditsCertification, reporting, and Control Section 11.90 established to share that risk with local government and other recipients of
CRF and comply with these federal requirements
State Responsibilities for CRF
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body testing
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19 and related expenses in
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Medical Expenses
Treatment of COVIDpublic hospitals or clinicsTemporary medical facilitiesTesting, including serological/antiEmergency medical response, including emergency medical transportationEstablishing
and operating public telemedicine capabilities
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Six Expenditure Categories
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19
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public health orders
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Public Health Expenses
Communication/enforcementAcquisition and distribution of medical and protective supplies (PPE/cleaning supplies) for various public health and safety staffDisinfection of public areas
and other facilitiesTechnical assistance on mitigation Public safety measures in response to COVIDQuarantining individuals
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Six Expenditure Categories
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to be
presumed 19
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Provide ready funding to address unforeseen financial needs and risks created by COVID
Substantially Dedicated Payroll Expenses
Includes: public safety, public health, health care, human services, and similar employeesPublic health and public safety are
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Six Expenditure Categories
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Less documentation of the work being performed if public health and public safety staffCARES Act does not allow backfill of lost revenue assume that these staff could be paid for by
the CRF, potentially freeing up general purpose funds (or offsetting lower receipts)Full payroll and benefits can be paid by CRF
Substantially Dedicated
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off
some discretion,
other staff:
Could include overtime if those additional hours are outside normal/historical dutiesThere is no percent threshold with appropriate documentation, like time keeping system or rationale
for change in duties/functionsCan use the CRF to other funds that may have incurred the initial expense
Substantially Dedicated
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19
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19.
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Staff stopped our program reviews to track federal funds related to COVIDStaff who could not telework were redeployed to help with UI program and set up for medical surgeStaff at all
state agencies being trained and redirected to support contact tracingIT staff that were directed to support COVIDtracking, reporting, and new online services previously requiring in
person visits
Examples at the state level:
Substantially Dedicated
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19:
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Comply with Public Health Measures and
Food delivery to seniors and vulnerable populationsTelework capabilities for public employeesProviding paid sick, paid family and medical leave to public employeesMaintaining county
jails such as sanitation and improvement of social distancing measuresCaring for homeless
4 Mitigate the Effects of COVID
Six Expenditure Categories
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payment of overdue
(UI) costs if those costs
federal government
insurance
reimbursed by
to small businesses for costs of business
Economic Support
Grants interruptionGrant or financial assistance rent/mortgage to avoid eviction or funeral expensePayroll support programUnemployment are not generally applies to local governments
using
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Six Expenditure Categories
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19
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term loan)
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Hazard pay and overtime if substantially dedicatedIncreased workers compensation costs due to COVIDLeases renewed solely to respond to COVIDPublic health emergency recovery planningSupport
for private hospitals (grant/shortEnrollment in government benefit programs
Other
Any other COVIDsatisfies the broader eligibility criteria:
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Six Expenditure Categories
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12/30/20)
be during the covered
must
Performance/delivery periodBulk purchases can be used beyond December if portion is used during the covered periodRecognizes supply chain disruptions may result in
December 30, 2020 (not just obligated)Recent revision (6/30/2020) allows for a liquidation period (generally 90 days)Grants and loans must be during this window
Costs Incurred (3/1
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Unspent funds must be returned to the US TreasurySubrecipients are also bound by this requirement that means all expenses must be incurred during the covered periodAn obligation or award
is not considered spentThe direct recipient of the funds (state) is ultimately responsible for compliance with this limitation on the use of the fundsUnspent funds may be reallocated
by the state based on September 1 expenditure reports
Unspent Funds
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Act match
Stafford
for certain costs and
federal
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Match for FEMA
CRF and FEMA eligibility must be met
both
may decide to not pay
Most recent Treasury guidance notes that CRF may be used to meet the nonApplicants for FEMA Public Assistance (PA) have flexibility to determine the federal fund source that best meets
response needsFEMA may direct entities to another agency/fund sourceFEMA has determined that contract tracing is more appropriately paid from either CRF or CDC funding.Coordinate closely
with CalOES to use CRF as a PA match
Stafford Act
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duplication of efforts by
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Use funds consistent with federal CARES ActAdhere to state EOs and California Department of Public Health orders, directives, and guidanceReport on expenditures and summarize regional
collaboration and nonSeptember 1, 2o20Return unspent funds by October 30, 2020 unless extended by Finance based on reported expendituresRepay any costs disallowed after federal reviewRetain
records (5 years) to support reported expenditures and participate in state and federal audits
All counties completed certification by 7/10/20
Process and Timeline (CS11.90)
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local leaders to
home orders
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collaborate with
at
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compliance
Monthly attestation for GF backfill of realigned programs will be used for compliance determinationFinance will coordinate with CDPH and CalOES to verify county complianceState may withhold
(and redirect) funds if not in complianceState officials will encourage No county ordinances or resolutions inconsistent
Adherence to Public Health Orders
Process and Timeline
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Counties Must Meet
At least 15 staff per 100,000 people trained and available for contract tracingAbility to isolate positive cases (quarantine contacts)Ability to shelter at least 15 percent of residents
who are experiencing homelessnessAbility to test 1.5 per 1,000 residents dailyTesting sites close to where most residents liveEvidence of a plan to contain the virus
Meeting current requirements for county variance:
Public Health Conditions
Process and Timeline
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Counties Must Meet
pharmaceutical
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Source of disease transmissionAction plan and timelines
Currently required commitment to participateUndertaking efforts advised by the state if on the County Data Monitoring ListReady to reinstitute noninterventions \[NPIs\] (e.g. closure
of indoor spaces) as needed
Actively participate in County Data Monitoring Program:
Public Health Conditions
Process and Timeline
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14 days
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likely before October 1
1/6 of overall amount ($215 M)
Prepare schedule and notification this weekGiven size of payment both the Controller and Treasurer have been notified to speed up processingController should allocate in 10
Initial Payment Additional 1/6 of overall amount to counties that remain in compliance on August 1 and September 1Balance of Funds ($650M) will paid after report and summary from counties
in compliance with health orders and federal laws
Process and Timeline
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assuming CRF will reimburse
Will need this for detailed federal report due 9/21Demonstrate a realistic plan for spending by the end of the year to avoid reallocation
Report to the State by September 1, 2020 per CS11.90Will cover expenditures from March 1, 2020 through June 30, 2020 Also report expended or obligated since July 1Project expenditures
through December 30, 2020Majority of funds expected to be spent early onSummary: regional collaboration/unduplicated costs
Reporting Process
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State (other direct recipients) must report on CRF expenditures between March 1 and June 30, 2020For the interim report (due July 17) the state would report on amount identified for
local governments
Reporting Process
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over $50K
9/30/20) due to
6/30/20)
recipient
By September 21, 2020 state must submit detailed quarterly report (3/1/20 Next quarterly report (7/1/20 federal government by October 13, 2020Current guidance requires reporting on funds
expended or obligated for each project or activityDetailed list (Name/Description) projects/activitiesDetailed list of loans issued; contracts and grants awarded; transfers to other
government entities; and direct payments made by
Quarterly Reporting Process
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12/30/20
final payment is made;
mail/electronic communications
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after
records 5 years
General ledger, subsidiary ledgerBudget records 2019 and 2020Payroll and time keeping recordsReceipts of purchasesContracts and subcontracts, including any performance outcomesDocumentation
of reports, audits, monitoring of recipientsAll CRF internal and external e
Retain make available on request for auditsAll documents and financial records sufficient to establish compliance: (1) Necessary, (2) Not in recent budget, (3) Incurred 3/1/20
Records Retention
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CFDA Number: 21.019Funds can be in interest bearing accounts; interest proceeds must be used for same purposesAssets purchased may be retained (e.g. homeless)Funds are subject to the
Single Audit ActMust follow Uniform Guidance regarding subrecipient monitoringFunds may be used to cover expense related to audit conducted under the Single Audit ActCompetitive bidding
is not required
Other CRF Information
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local
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and
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issues/cares/state
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Unit:
Reporting/Research
Local Government Unit: CRFApplications@dof.ca.govFederal COVIDFederalTracking@dof.ca.govGF Realignment Backfill:CountyGFAllocations@dof.ca.govUS Treasury/OIG CRF Information: https://home.treasury.g
ov/policygovernments